 Version: 1.0

 Date: July 6, 2021

 Prepared for: USDA OCIO-Policy, 

E-Government and Fair Information 

Practices (PE&F)

Policy, E-Government and Fair Information Practices 

Privacy Impact Assessment 

Operations and Reporting System (OARS)
Privacy Impact Assessment – Guidance and Template 

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Privacy Impact Assessment for the 

Wildlife Services Operations and Reporting System 

(OARS) 

July 6, 2021

Contact Point 

David Reinhold 

USDA APHIS Wildlife Services 

301-851-4002 

Reviewing Official 

Tonya Woods, APHIS Privacy Act Officer 

USDA APHIS 

301-851-4076
Privacy Impact Assessment – Guidance and Template 

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Abstract 

This Privacy Impact Assessment (PIA) is developed for the USDA APHIS Wildlife Services 

(WS) Operations and Reporting System (OARS). OARS is being implemented as a new system 

of records for documentation and tracking of business conducted by (WS) in its operational 

program in cooperative relationships with government, business/industry, and private 

individuals. Once approved and implemented, OARS will replace WS Management 

Information System (MIS) as the official system of record for documentation and tracking 

program business. This PIA is being conducted to both report to the government and the public 

about the system, and to evaluate the system’s conformity to privacy and information collection 

mandates. 

Overview 

As part of the modernization effort, the Animal and Plant Health Inspection Service (APHIS), 

WS OARS application system is built based on a cloud solution to better serve the APHIS WS 

program, its customers, and the public, by improving the program’s capability to monitor and 

measure program performance; provide timely information to decision makers; and better 

document APHIS WS work. 

The OARS WS users will have the option of using a desktop component or a mobile application. 

Both the front end mobile and desktop components will be synced via a layer of support services 

that also handles the program logic. 

OARS is especially important for record keeping of work in several areas of wildlife damage 

management related to agriculture, human health and safety, natural resources, and human 

property. These areas include, but are not limited to, wildlife diseases, airports, invasive species, 

livestock protection, blackbird damage management, and aquaculture protection. The current 

system of record, MIS, is the only data management system dedicated to tracking APHIS WS 

work and accomplishments nationwide. APHIS WS has a strong interest in protecting the 

privacy of both its customers and employees as the new system is developed and maintained. 

OARS will serve a data tracking and management system and it will enable managers to have 

access to valuable data at the click of a button. It assists program management by enabling 

operations personnel to gather data that in the past could not be collected. It provides APHIS 

WS employees with the capability to generate specialized reports for their cooperators without 

the assistance of support personnel. It facilitates better information gathering and distribution, 

internally for decision makers and externally for all interested parties. 

A typical transaction in OARS occurs when WS employees enter information related to wildlife 

damage management projects they conduct in the field. This information may include data 

about direct damage management work or technical assistance projects. 

 
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While WS provides no direct access to the system or its components to other entities, the WS 

program does share some information collected by employees and entered into the system. This 

sharing is a manual process and may be be shared on an excel spreadsheet. This may include: 

• Agencies which collaborate with APHIS WS in implementation of, or Agencies which 

regulate, wildlife management projects/programs, or who have an interest, or regulate, 

in animal or public health, or national security may request data in the OARS to be 

shared. 

• State or Federal government-level representatives of the Environmental Protection 

Agency as part of APHIS WS’ responsibility to comply with the Federal Insecticide 

Fungicide and Rodenticide Act (U.S. Code Title 7, Section 136i-1). 

• Some data provided to land management agencies, such as the Bureau of Land 

Management (BLM) and the Forest Service (FS), where a cooperator has a grazing 

allotment also require information about wildlife damage management actions 

performed on the agencies managed lands. 

The OARS system of records features a companion module for tracking pesticide usage by WS, 

the Control Materials Inventory Tracking System (CMITS). This module accommodates data 

entry about the use of chemical applications and inventories. 

Authority for maintaining OARS as a system of record resides in the Act of March 2, 1931 as 

amended (46 Stat. 1468-69; 7 U.S.C. §§ 8351-8352) and The Act of December 22, 1987 (Public 

Law No. 100-202, § 101(k), 101 Stat. 1329-331, 7 U.S.C. § 8353).

Section 1.0 Characterization of the Information 

The following questions are intended to define the scope of the information requested and/or 

collected as well as reasons for its collection as part of the program, system, rule, or technology 

being developed. 

1.1 What information is collected, used, disseminated, or maintained in 

the system? 

The following information is collected and maintained/updated in the system: 

 Customer (Cooperator) Data: This is the minimal information kept by WS which is 

necessary for identifying cooperators for the purpose of communication with them and 

tracking of work performed by WS employees as part of a program being conducted in 

collaboration with them. This usually includes a name, telephone number, email 

address, physical location address, and specific wildlife damage management projects. 

Information about cooperators may also include resources and property that were 

threatened, damaged, or destroyed by wildlife, values of resources or property and 

adverse human or animal incident information. In some instances, GPS coordinates may 

be recorded for locations on properties where specific damage management actions, 

such as wildlife disease sampling or placing of some devices. 
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 Employee data: This is minimal and includes name, address and telephone number of 

duty station, username, and OARS unique employee identification number generated by 

the system. 

 Other data: Information in the system may relate to resources owned by customers 

which was threatened, damaged or destroyed by wildlife. 

1.2 What are the sources of the information in the system? 

Data is generated as a result of entries made about the work performed by WS Employees. 

Other data is collected by WS through voluntary submission by customers that may include 

personal communication. This data is entered into the system by WS employees. Reference and 

lookup information about pesticide registration, wildlife laws and permits are obtained from 

federal, state, and local authorities. A geodatabase containing publicly available land ownership 

and property boundary maps will be procured from a third-party commercial provider and 

linked to the system. 

1.3 Why is the information being collected, used, disseminated, or 

maintained? 

The information collected by APHIS WS is necessary for identifying cooperators for the 

purpose of communicating with them and tracking work performed by WS employees as part 

of a program being conducted in collaboration with them. This includes a name, telephone 

number, email address or physical location address. 

Information is also collected because Agency procedure requires that WS employees obtain 

permission to enter the property of cooperators. Information collected about cooperators will 

be used to document authority and license to enter premises to conduct wildlife damage 

management work, pursuant to requests from cooperators for services to be conducted on their 

behalf. In addition, WS managers need to evaluate the effectiveness of program work being 

conducted by federal, state, and contractor personnel as program actions occur on cooperator 

property or on behalf of the cooperator. Information collected about the cooperator will help 

managers conduct such evaluations. 

Also, in support of the APHIS mission, WS gathers information from cooperators about how 

and when work will be performed, what methods will be used, and what information to provide 

the cooperator about the methodology, process, frequency, results, and time lines to be used in 

program work, and to assist in developing safety measures and protocols. 

1.4 How is the information collected? 

Information is collected for the system through direct contact by WS employees with 

cooperators. WS employees gather information from cooperators and enter information directly 

into OARS using electronic forms, or on paper forms that are subsequently entered into OARS. 

Other information is collected from WS employees who have direct knowledge about 

operational work performed and information about themselves. 
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Some information is collected about wildlife and wildlife damage management subjects from 

sources made available by local, state, or federal government entities, or is general information 

published on the web. 

1.5 How will the information be checked for accuracy? 

Employees validate information through a screen review process before permitting its entry into 

the system. Customers will validate all information collected about themselves on the WS 

FORM 12A and then sign it to agree that the information is accurate. Additionally, there is 

review by APHIS WS supervisors and data specialists at the district, state, regional and national 

levels. 

Signed paper forms containing data collected from customers (cooperators) will be checked by 

them at signature. The APHIS WS employee collecting the data will be reviewed by another 

WS employee before being "approved" in the system. Field work data will be checked for 

completeness by the APHIS WS employee who enters it. This electronic data entry process is 

monitored by an internal validation prompt system built into the OARS. Data is again reviewed 

for accuracy by supervisors at the APHIS WS district and state levels. 

Data of this type will be verified for accuracy, relevance, timeliness, and completeness by 

APHIS WS employees in their contact with agencies and entities providing the information. 

1.6 What specific legal authorities, arrangements, and/or agreements 

defined the collection of information? 

The following legal authorities require collection of certain information in OARS: 

1) The Act of March 2, 1931 as amended (46 Stat. 1468-69; 7 USC §§ 8351-8352); 

and 

2) The Act of December 22, 1987 (Public Law No. 100-202, § 101(k), 101 Stat. 

1329-331, 7 USC § 8353) In addition, WS enters into agreements with cooperators 

in the private and public sectors in which such cooperators agree by signature to 

submit the information collected. The agreements include Memoranda of 

Understandings, Memoranda of Agreements, Cooperative Service Agreements, 

and Cooperative Service Field Agreements. 

1.7 Privacy Impact Analysis: Given the amount and type of data 

collected, discuss the privacy risks identified and how they were 

mitigated. 

Privacy information collected about WS employees and cooperators is protected through a 

number of mitigation efforts that include information access control, and system protocols. Data 

consolidation has the potential to create privacy risks; however, data consolidation in OARS is 

an in-house initiative in the APHIS WS system. Individuals involved in all processes are 

restricted to data that they are authorized to handle, and the data is not exposed to any 
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unauthorized users during this process. Standard safeguards approved by USDA for data 

security are used to reduce the likelihood of unauthorized access or use. 

Other controls to protect data from unauthorized access include unique user identification, eAuthentication, Agency implemented cybersecurity measures and firewalls installed at each 

access terminal, current virus protection programs updated in accordance with Agency 

requirements, and immediate lockout capability if a user is disqualified from access to data at 

any level. All transfer of data occurs through the Agency’s standard virtual private network 

(VPN) in encrypted formats. Hard copy components of the system are segregated and protected 

in secured and locked storage cabinets accessible only to authorized users. Other internal 

safeguards include monitoring of data management and development processes by the ISSM 

and ISSOs, and supervisory controls for field level data entry and handling. 

Section 2.0 Uses of the Information 

The following questions are intended to delineate clearly the use of information and the 

accuracy of the data being used. 

2.1 Describe all the uses of information. 

OARS will support WS’ mission to provide services necessary to manage wildlife damage to 

protect agriculture, natural resources, property, and human health and safety. These areas 

include but are not limited to wildlife diseases, airports, invasive species, livestock protection, 

blackbird damage management, and aquaculture protection. The WS Program supports the 

APHIS mission to safeguard the health, welfare, and value of American agriculture and 

natural resources. APHIS and WS will use OARS to maintain a record of activities conducted 

by program personnel and cooperators pursuant to its mission and responsibilities. OARS will 

serve as a data tracking and management system and it will enable managers to have access to 

valuable wildlife damage management data. It provides WS personnel with the capability to 

generate specialized reports for their cooperators. It facilitates better information gathering 

and distribution, internally for decision makers and externally for all interested parties. 

Additionally, collected information will be used to generate wildlife damage management 

reports for the general public and agency stakeholders. Reports made available to the general 

public will not contain personal identifying information or distinguishable locations 

disclosures. APHIS WS has a statutory requirement to protect the privacy of both its 

customers and employees. OARS will also include a Control Materials Inventory Tracking 

System (CMITS), used for tracking the inventory and WS’ usage of pesticides, pyrotechnics, 

explosives and other restricted items. 

2.2 What types of tools are used to analyze data and what type of data 

may be produced? 

WS uses a suite of analytical tools including statistical software, database management, 

spreadsheets and geospatial tools to analyze program data. Analyses include descriptive 

statistics and data showing trends in wildlife damage management effects, wildlife damage 
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impacts, and results of work. No personal data about cooperators is subjected to analysis since 

data sets used are stripped and consolidated. Managers in WS may use data about hours 

worked by field employees to analyze time spent on projects or other efficiency metrics 

related to field work or technical assistance projects. 

2.3 If the system uses commercial or publicly available data please 

explain why and how it is used. 

OARS will integrate commercially available geospatial products depicting land ownership and 

property boundaries of public and privately owned lands (parcel data). This parcel data is 

publicly available at the county level but is curated by commercial vendors to provide single 

source national level data. The maps will be used to identify properties where the Program has 

permission to conduct wildlife damage management. Parcel data will not be made available to 

the public. 

2.4 Privacy Impact Analysis: Describe any types of controls that may be 

in place to ensure that information is handled in accordance with the 

above described uses. 

Analyses are done by request from WS supervisory staff or other entities who have requested 

such information through official channels. Such information is purged of any privacy 

information and is checked to ensure that outputs do not point to private individuals or their 

information. 

Lookup and reference information is used only by those who have been approved by the ISSM 

and entries of lookup data are automated to provide unaltered data. 

Section 3.0 Retention 

The following questions are intended to outline how long information will be retained after the 

initial collection. 

3.1 How long is information retained? 

Information in the OARS is permanent until the disposition authority is approved by NARA. 

In November 2020, APHIS Records Management submitted WS’ retention schedule for the 

current System of Record, MIS2000, to NARA. The request was returned without actions. On 

June 23, 2021, APHIS emailed NARA requesting what actions need to be accomplished for 

schedule approval. Once completed and approved OARS will replace the legacy system 

MIS2000, as the official system of record. 

The proposed schedule is as follows: 

a. Customer data, both paper and electronic, is collected personally and may be entered into 

the system. 
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(Customer data is information about the cooperator including mailing address, phone number, 

number of acres, and resources protected.) 

Personal Customer data will never be collected in a field journal. Fieldwork data maybe 

collected in a field journal but is required to be destroyed after input into the System of Record. 

Disposition: Electronic. Updated by consultation with customer while account is active. 

(Information is updated in the system continually while the employee works with the cooperator 

regarding the management of wildlife damage and resources to be protected.) 

b. Employee data entered directly into the system. 

Disposition: Updated at least annually by employees. Data records cutoff is at the end of the 

FY in which the case or project file is closed or by expiration date on document. Destroy 5 

year(s) after cutoff (If approved by NARA). 

Information is retained about employees as long as they are actively employed by the unit, or 

as long as their project-related work history is kept in the system. Reference and lookup 

information is kept in the system as long as it is used by employees to populate record material. 

In general, records are retained in accordance with data elimination procedures outlined by 

NARA guidelines. 

 

3.2 Has the retention period been approved by the component records 

officer and the National Archives and Records Administration (NARA)? 

In November 2020, APHIS Records Management submitted WS’ retention schedule for the 

current System of Record, MIS2000, to NARA. The request was returned without actions. On 

June 23, 2021, APHIS emailed NARA requesting what actions need to be done for schedule 

approval. 

3.3 Privacy Impact Analysis: Please discuss the risks associated with the 

length of time data is retained and how those risks are mitigated. 

Private data information is only accessible to personnel working on that particular project or 

property. When the project is complete or services are no longer required, OARS data 

managers remove personnel access to the private information. The risk to private data while 

the project is active is low. 

Section 4.0 Internal Sharing and Disclosure 

The following questions are intended to define the scope of sharing within the United States 

Department of Agriculture. 

4.1 With which internal organization(s) is the information shared, what 

information is shared and for what purpose? 
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WS Program personnel will be able to generate reports using information from OARS. No 

other USDA organization will have direct access to the system except APHIS Market and 

Regulatory Programs Information Technology (MRP IT) – To resolves software issues. 

Reports generated for USDA organizations using information from OARS include: 

 USDA Natural Resources Conservation Services (NRCS) – Cooperative Feral swine 

damage management information. The agency partnership authorized by the 2018 

Farm Bill. 

 USDA Office of General Counsel if it pertains to a legal process or litigation actions. 

 USDA Farm Services Agency- Information may be provided to FSA under the 

Livestock Indemnity Program (LIP). 

4.2 How is the information transmitted or disclosed? 

WS transmits/discloses PDF or read only web display to USDA organizations. 

4.3 Privacy Impact Analysis: Considering the extent of internal 

information sharing, discuss the privacy risks associated with the 

sharing and how they were mitigated. 

Privacy risks associated with internal sharing are mitigated through handling procedures which 

ensure that information released is only what is requested, is legally allowed to be released, and 

is securely passed directly to the authorized recipient or their official agents. 

Section 5.0 External Sharing and Disclosure 

The following questions are intended to define the content, scope, and authority for 

information sharing external to USDA which includes Federal, state and local government, 

and the private sector. 

5.1 With which external organization(s) is the information shared, what 

information is shared, and for what purpose? 

1) To cooperative federal, state, local, and tribal government officials, employees, or 

contractors, and other parties as necessary to carry out the program; and other parties 

engaged to assist in administering the program. Such contractors and other parties will 

be bound by the nondisclosure provisions of the Privacy Act. This routine use assists the 

agency in carrying out the program, and thus is compatible with the purpose for which 

the records are created and maintained; 

2) To federal, state, tribal, and local regulatory agencies and their employees and 

contractors who collaborate with WS in implementation of, or agencies that regulate, 

wildlife management projects or programs, or who have an interest in, or regulate, 

animal or public health, wildlife species conservation, or national security; 
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3) To land management agencies, such as the Bureau of Land Management, the U.S. Fish 

and Wildlife Service, U.S. Forest Service, U.S. Department of Defense, and state, local, 

and tribal land management programs relating to, but not limited to, wildlife damage on 

grazing allotments, recreational lands (parks), and property; species conservation 

projects; or disease surveillance; 

4) To consumer reporting agencies in accordance with section 31 U.S.C. 3711(e); 

5) To state or federal government-level representatives of the U.S. Environmental 

Protection Agency, in compliance with the Federal Insecticide, Fungicide, and 

Rodenticide Act (FIFRA) mandate (FIFRA Sec. 8, 7 U.S.C. 136f, and FIFRA 7 U.S.C. 

136i-l), of the location on a cooperator's property where certain regulated pesticide 

devices are deployed or regulated pesticides are applied; 

6) To cooperating laboratories, federal, state, and local government officials, employees, or 

contractors, and other parties engaged to assist in administering animal health programs 

to assist the agency in carrying out the program. 

7) To USDA contractors or cooperators with signed agreements collaborating with USDA 

in conducting, managing, or evaluating wildlife disease or pest surveillance or control 

programs, and monitoring for animal issues, diseases, or pests or to aid in containing 

and responding to a foreign or domestic animal disease outbreak, zoonotic disease 

outbreak, bioterrorism, radiological event, or other animal health emergency; 

8) To a congressional office in response to an inquiry from that congressional office made 

at the written request of the individual about whom the record pertains; 

9) To contractors and their agents, grantees, experts, consultants, and others performing or 

working on a contract, service, grant, cooperative agreement, or other assignment for 

USDA, when necessary to accomplish an agency function related to this system of 

records. 

10) To the Department of Justice when: (a) USDA, or any component thereof; or (b) any 

employee of USDA in his or her official capacity, or any employee of the agency in his 

or her individual capacity where the Department of Justice has agreed to represent the 

employee; or (c) the United States Government, is a party to litigation or has an interest 

in such litigation, and USDA determines that the records are relevant and necessary to 

the litigation and the use of such records by the Department of Justice is for a purpose 

that is compatible with the purpose for which USDA collected the records; 

11) In an appropriate proceeding before a court, grand jury, or administrative or adjudicative 

body or official, when USDA or other Agency representing USDA determines that the 

records are relevant and necessary to the proceeding; or in an appropriate proceeding 

before an administrative or adjudicative body when the adjudicator determines the 

records to be relevant to the proceeding; 

12) To appropriate agencies, entities, and persons when: (a) USDA suspects or has 

confirmed that there has been a breach of system of records; (b) USDA has determined 

that as a result of the suspected or confirmed breach there is a risk of harm to 

individuals, USDA (including its information systems, programs, and operations), the 

Federal Government, or national security; and (c) the disclosure made to such agencies, 

entities, and persons is reasonably necessary to assist in connection with USDA’s efforts 

to respond to the suspected or confirmed compromise and prevent, minimize, or remedy 

such harm; 
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13) To appropriate law enforcement agencies, entities, and persons, whether Federal, 

foreign, State, Tribal, local, or other public authority responsible for enforcing, 

investigating, or prosecuting an alleged violation or a violation of law or charged with 

enforcing, implementing, or complying with a statute, rule, regulation, or order issued 

pursuant thereto, when a record in this system on its face, or in conjunction with other 

records, indicates a violation or potential violation of law, whether civil, criminal, or 

regulatory in nature, and whether arising by general statute or particular program statute, 

or by regulation, or rule, or court order issued pursuant thereto, if the information 

disclosed is relevant to any enforcement, regulatory, investigative, or prosecutive 

responsibility of the receiving entity; 

14) To another Federal agency or Federal entity, when information from this system of 

records is reasonably necessary to assist the recipient agency or entity in (a) responding 

to a suspected or confirmed breach or (b) preventing, minimizing, or remedying the risk 

of harm to individuals, the recipient agency or entity (including its information systems, 

programs, and operations), the Federal Government, or national security, resulting from 

a suspected or confirmed breach; 

15) To USDA contractors, partner agency employee or contractors, or private industry 

employed to identify patterns, trends, or anomalies indicative of fraud, waste, or abuse; 

and 

16) To the National Archives and Records Administration (NARA) or to the General 

Services Administration for records management activities conducted under 44 U.S.C. 

2904 and 2906. 

5.2 Is the sharing of personally identifiable information outside the 

Department compatible with the original collection? If so, is it 

covered by an appropriate routine use in a SORN? If so, please 

describe. If not, please describe under what legal mechanism the 

program or system is allowed to share the personally identifiable 

information outside of USDA. 

The sharing of personally identifiable information outside USDA is compatible with the 

original collection and is covered by routine uses declared in the WS SORN Docket No. 

APHIS-9 Wildlife Service Management Information System and Operations and Reporting 

System. 

5.3 How is the information shared outside the Department and what 

security measures safeguard its transmission? 

Information shared and transmitted outside USDA may be done by direct contact, or through 

encrypted email, standard mailing procedures, or in some instances by phone. Rules and 

guidance for protection of such shared information is provided in Sections 3.7 and 6.0 of the 

WS Information Data Management Handbook (IDMH). Email transfers have warning 
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disclaimers attached which notify recipients about security considerations and instruct 

recipients who erroneously receive such transmissions to delete them. 

5.4 Privacy Impact Analysis: Given the external sharing, explain the 

privacy risks identified and describe how they were mitigated. 

A potential risk to information resulting from external sharing would be transmittal of 

unauthorized material or transmittal to unauthorized parties. WS uses a policy-controlled, tiered 

approval process that ensures evaluation of all aspects of the transmittal process to validate the 

appropriateness and legality of such information transfer. 

Section 6.0 Notice 

The following questions are directed at notice to the individual of the scope of information 

collected, the right to consent to uses of said information, and the right to decline to provide 

information. 

6.1 Does this system require a SORN and if so, please provide SORN 

name and URL. 

Yes. Wildlife Services, Management Information System and Operations and 

Reporting System. (pending new SORN approval) 

A new SORN covering the old system of record MIS2000 and OARS is under 

development. The MIS2000 SORN is available. 

6.2 Was notice provided to the individual prior to collection of 

information? 

Yes 

6.3 Do individuals have the opportunity and/or right to decline to provide 

information? 

Yes 

6.4 Do individuals have the right to consent to particular uses of the 

information? If so, how does the individual exercise the right? 

Individuals have the opportunity during the collection process to review uses that may 

be made of the information and declare and document special considerations related to 

use of information. 
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6.5 Privacy Impact Analysis: Describe how notice is provided to 

individuals, and how the risks associated with individuals being 

unaware of the collection are mitigated. 

Upon request for information from contributors, WS provides an information sheet 

defining the uses to be made of any submissions. To mitigate risks that individual 

contributors might be unaware of the collection, the use and purpose of the collection is 

discussed by WS employees and questions by the contributor are encouraged. 

Section 7.0 Access, Redress and Correction 

The following questions are directed at an individual’s ability to ensure the accuracy of the 

information collected about them. 

7.1 What are the procedures that allow individuals to gain access to their 

information? 

§1.112 Procedures for requests pertaining to individual records in a record 

system. 

(a) Any individual who wishes to be notified if a system of records maintained by an 

agency contains any record pertaining to him or her, or to request access to such records, 

shall submit a written request in accordance with the instructions set forth in the system 

notice for that system of records. 

Under the Privacy Act (PA) of 1974 (5 U.S.C. §552a), a person may seek access to 

records that are retrieved by his/her own name or other personal identifiers, such as 

social security number or employee identification number. Such records will be made 

available unless they fall within the exemptions of the PA or the Freedom of Information 

Act (FOIA). 

Your request must be in writing. Indicate that you are making a request under the PA. 

Address the request to the following address: 

VIA MAIL: 

Animal and Plant Health Inspection Service 

Director, Freedom of Information and Privacy Act Staff 

4700 River Road, Unit 50 

Riverdale, MD 20737 

VIA FACSIMILE: 301-734-5941 

VIA E-MAIL: APHISPrivacy@usda.gov

NOTE: While e-mail attachments are often an important and legitimate means of 

conducting business, they also have the potential to cause great harm to our e-mail 
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infrastructure, as well as to individual workstations. Please place the text of your PA 

request into the ‘body’ of the email message. 

The USDA Privacy Policy can be located at the following: 

URL: https://www.usda.gov/privacy-policy

Information about FOIA requests can be found at: 

https://www.aphis.usda.gov/aphis/resources/lawsandregs/privacy-act/privacy

7.2 What are the procedures for correcting inaccurate or erroneous 

information? 

Customers may correct inaccurate or erroneous information by submitting a Privacy Act 

request to: APHIS Privacy Act Office, 4700 River Road, Unit 50, Riverdale, MD 20737 

or email the Privacy Act Officer at APHISPrivacy@usda.gov. APHIS employees can 

update contact information through the Address Book Tool, which updates the 

Enterprise Active Directory (EAD) and in turn updates the APHIS ServiceNow profile. 

External customers’ information is corrected through communication via the Helpdesk. 

The USDA Privacy Policy can be located at the following URL: 

https://www.usda.gov/privacy-policy. 

Information about FOIA requests can be found at: 

https://www.aphis.usda.gov/aphis/resources/foia/ct_how_to_submit_a_foia_request

7.3 How are individuals notified of the procedures for correcting their 

information? 

Procedures for correcting information in the system can be found in the APHIS-9 

Wildlife Service Management Information System SORN or 

 https://www.aphis.usda.gov/aphis/resources/foia/ct_how_to_submit_a_foia_request

7.4 If no formal redress is provided, what alternatives are available to the 

individual? 

N/A 

7.5 Privacy Impact Analysis: Please discuss the privacy risks associated 

with the redress available to individuals and how those risks are 

mitigated. 

There is some risk that the contributor’s information would fail to be corrected by initial 

processes, but the multi-level redress alternatives available to the contributor makes this 

outcome extremely unlikely. There is also a limited risk that the corrected privacy 
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information could also be erroneous, but documentation to the contributor from WS 

ensures that the corrected information is available for review and approval by the 

contributor. 

Section 8.0 Technical Access and Security 

The following questions are intended to describe technical safeguards and security measures. 

8.1 What procedures are in place to determine which users may access 

the system and are they documented? 

Procedures in place to determine which users may access the system include unique user 

identification, two-factor authentication (eAuth – SiteMinder), agency implemented 

cybersecurity measures, and firewalls installed at each access point. When employees 

are disqualified from access to the system or any sector of the data, there is an immediate 

lockout capability. Prior to the OARS going live, documentation of procedures will be 

available in the OARS Rules of Behavior and OARS Security Features User’s Guide in 

the WS IDMH as appendices. 

8.2 Will Department contractors have access to the system? 

Yes 

8.3 Describe what privacy training is provided to users either generally 

or specifically relevant to the program or system? 

Users are required to take annual departmental/agency privacy training. All new users 

are also given orientation by the ISSM, ISSM representatives, or supervisors on 

protecting privacy in the WS system of records.

8.4 Has Certification & Accreditation been completed for the system or 

systems supporting the program? 

No, it is currently beginning its initial Certification and Accreditation (C&A) to obtain its 

Authority to Operate (ATO). 

8.5 What auditing measures and technical safeguards are in place to 

prevent misuse of data? 

The system automatically records an audit trail which identifies logon and data change 

or data entry actions. Routine monitoring of audit records is done. 

8.6 Privacy Impact Analysis: Given the sensitivity and scope of the 

information collected, as well as any information sharing conducted 
Privacy Impact Assessment – Guidance and Template 

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on the system, what privacy risks were identified and how do the 

security controls mitigate them? 

There is a very slight risk that WS field employees could gain access to privacy 

information, such as names and addresses of cooperators which they do not service. 

However, access to accounts by non-servicing employees must be granted by security 

personnel and by supervisors of both the servicing employees and those employees 

seeking access. Further, any access to privacy data in the system is only available to 

certain WS personnel and that by use of the least privileged rule. 

Section 9.0 Technology 

The following questions are directed at critically analyzing the selection process for any 

technologies utilized by the system, including system hardware and other technology. 

9.1 What type of project is the program or system? 

A web-based and mobile-app direct data entry system of records.

9.2 Does the project employ technology which may raise privacy 

concerns? If so please discuss their implementation. 

Because this project is online-based application with web and mobile components, there 

is some risk that unauthorized intruders could gain access to privacy information. 

However, the system resides behind the APHIS firewall, and is protected by 

eAuthentication access protocols. Users are granted initial access through a tiered 

approval process which provides layers of validation, and only employees supervised 

by WS can become users with access into the system. 

Section 10.0 Third Party Websites/Applications 

The following questions are directed at critically analyzing the privacy impact of using third 

party websites and/or applications. 

10.1 Has the System Owner (SO) and/or Information Systems Security 

Program Manager (ISSPM) reviewed Office of Management and 

Budget (OMB) memorandums M-10-22 “Guidance for Online Use of 

Web Measurement and Customization Technology” and M-10-23 

“Guidance for Agency Use of Third-Party Websites and 

Applications”? 

Yes 
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10.2 What is the specific purpose of the agency’s use of 3rd party websites 

and/or applications? 

WS does not use 3rd party websites or applications for conducting business or contact 

initiatives. 

10.3 What personally identifiable information (PII) will become available 

through the agency’s use of 3rd party websites and/or applications. 

N/A 

10.4 How will the PII that becomes available through the agency’s use of 

3

rd party websites and/or applications be used? 

N/A 

10.5 How will the PII that becomes available through the agency’s use of 

3

rd party websites and/or applications be maintained and secured? 

N/A 

10.6 Is the PII that becomes available through the agency’s use of 3rd party 

websites and/or applications purged periodically? 

N/A 

If so, is it done automatically? 

N/A 

If so, is it done on a recurring basis? 

N/A 

10.7 Who will have access to PII that becomes available through the 

agency’s use of 3rd party websites and/or applications? 

N/A 

10.8 With whom will the PII that becomes available through the agency’s 

use of 3rd party websites and/or applications be shared - either 

internally or externally? 

N/A 
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10.9 Will the activities involving the PII that becomes available through 

the agency’s use of 3rd party websites and/or applications require 

either the creation or modification of a system of records notice 

(SORN)? 

N/A 

10.10 Does the system use web measurement and customization technology? 

N/A 

If so, is the system and procedures reviewed annually to demonstrate compliance to 

OMB M-10-23? 

N/A 

10.11 Does the system allow users to either decline to opt-in or decide to 

opt-out of all uses of web measurement and customization 

technology? 

N/A 

If so, does the agency provide the public with alternatives for acquiring comparable 

information and services? 

N/A 

10.12 Privacy Impact Analysis: Given the amount and type of PII that 

becomes available through the agency’s use of 3rd party websites 

and/or applications, discuss the privacy risks identified and how they 

were mitigated. 

N/A 
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Responsible Officials 

David S. Reinhold, Director WS OSS 

System Owner 

Steve Kendrot, Deputy Director WS OSS 

Product Owner 

Approval Signature 

________________________________ 

MRP-IT ISSPM 

Animal and Plant Health Inspection Service 

United States Department of Agriculture 

________________________________ 

APHIS Privacy Act Officer 

Animal and Plant Health Inspection Service 

United States Department of Agriculture 

________________________________ 

David S. Reinhold 

APHIS WS Director OSS 

System Owner 

United States Department of Agriculture.